Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
EDD collected in SVB-related provisional assessments was a refundable deposit and not customs duty; once the related-party valuation issue was concluded in favour of the importer, refund could not be withheld pending finalisation of other Bills of Entry issues such as test reports, demurrage or quantity variations. The Tribunal held that the statutory scheme governing provisional assessment and refund applied to EDD, and rejected the departmental view that all assessments had to be finalised before refund. It further held that the refund application was complete in material respects, so delay in sanctioning refund attracted interest under Section 27A from expiry of three months after receipt of the claim until actual refund.
EDD collected in SVB-related provisional assessments was a refundable deposit and not customs duty; once the related-party valuation issue was concluded in favour of the importer, refund could not be withheld pending finalisation of other Bills of Entry issues such as test reports, demurrage or quantity variations. The Tribunal held that the statutory scheme governing provisional assessment and refund applied to EDD, and rejected the departmental view that all assessments had to be finalised before refund. It further held that the refund application was complete in material respects, so delay in sanctioning refund attracted interest under Section 27A from expiry of three months after receipt of the claim until actual refund.
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